News & Analysis as of

Lead Generators Consumer Financial Protection Bureau (CFPB)

Goodwin

CFPB Q1 Circular Recap: Essential Takeaways for Mitigating UDAAP Risk to Remittance Transfer Providers, Digital...

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In the first quarter of 2024, the Consumer Financial Protection Bureau (CFPB) issued two Consumer Financial Protection Circulars, putting remittance transfer providers, digital comparison-shopping tools operators, and lead...more

Venable LLP

Why the CFPB’s Preferencing and Steering Practices Circular Should Scare Lead Generators and Consumer Financial Services Providers

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If you’ve been focused on only the high-level statements from the CFPB, you might already expect Rohit Chopra to fashion himself and the agency as “pro-consumer.” Consistent with that approach, the agency just signaled its...more

BakerHostetler

Steering into Dark Patterns

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Sometimes you hear grumbling that Leap Day shouldn’t mean an extra day of work – but not at the CFPB. The agency celebrated Feb. 29 this year by issuing guidance regarding “steering.”...more

Ballard Spahr LLP

CFPB Press Release and Circular cite “abusive” steering practices in connection with comparison-shopping tools and lead generators

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On February 29, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued Consumer Financial Protection Circular 2024-01, Preferencing and steering practices by digital intermediaries for consumer financial products or...more

Sheppard Mullin Richter & Hampton LLP

The CFPB Takes Aim at Digital Comparison Shopping Websites and Lead Generators

On February 29, the CFPB issued a circular warning digital comparison-shopping websites and lead generators that practices that steer customers to certain financial products or services based on compensation received from...more

Troutman Pepper

CFPB Warns Digital Comparison-Shopping Operators and Lead Generators That Steering Consumers Could Violate the CFPA, But Fails to...

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Can digital comparison-shopping operators or lead generators violate the Consumer Financial Protection Act (CFPA) by preferencing products or services based on financial benefit? According to today’s guidance issued by the...more

Venable LLP

Lead Generation: An Excerpt from the Advertising Law Tool Kit

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In the evolving world of lead generation and performance-based customer acquisition, the quest for profits can lead to big legal risks, some of them too large for advertisers that buy leads through third parties. Advertisers...more

Shipkevich PLLC

California DFPI Proposes Regulation to Implement Registration Requirements for Entities Covered Under California Consumer...

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The California Consumer Financial Protection Law (“CCFPL”), established in September of 2020 under Governor Newsom, augmented the Department of Financial Protection & Innovation’s (“DFPI”) authoritative ability by increasing...more

Ballard Spahr LLP

Minnesota AG files lawsuit against pension advance companies

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The Minnesota Attorney General announced that she has filed a lawsuit in state court against two pension advance companies. According to the AG’s press release, the companies often solicited borrowers through their own...more

Foley & Lardner LLP

The CFPB's Prospect RESPA Consent Orders: Eight Key Takeaways

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The Consumer Financial Protection Bureau (CFBP) on January 31, 2017, issued consent orders settling enforcement claims that a major mortgage lender violated the Real Estate Settlement Procedures Act (RESPA) in connection with...more

Manatt, Phelps & Phillips, LLP

Consumer Financial Services Law - October 2016

Court to CFPB: Unconstitutional and Wrong on RESPA - The U.S. Court of Appeals for the D.C. Circuit has declared unconstitutional a core component of the structure of the Consumer Financial Protection Bureau (CFPB) and...more

Ballard Spahr LLP

FTC staff paper on lead generation likely to inform CFPB

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Almost a year ago, on October 30, 2015, the FTC conducted a workshop on lead generation entitled to “Follow the Lead.” We published a three-part series on the workshop highlighting the key takeaways. On September 15, 2016,...more

Goodwin

Financial Services Weekly News - April 2016 #4

Goodwin on

Regulatory Developments - Federal Banking Regulators Propose Net Stable Funding (Liquidity) Ratio - The Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation...more

Baker Donelson

CFPB's Latest Action is Against the Co-Founders of a Lead Aggregator

Baker Donelson on

On April 21 the Consumer Financial Protection Bureau (CFPB) brought its latest enforcement action by filing a civil suit in the United States District Court for the Central District of California (CDCA) against Dmitry...more

Robins Kaplan LLP

DOJ Takes On Tribal Lending: Inside The Indictments

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In recent months, the attention of the tribal lending industry has focused on the Consumer Financial Protection Bureau’s emerging role in regulating short-term loans from sovereign tribal nations, but a new and even more...more

Ballard Spahr LLP

FTC sends 2015 ECOA report to CFPB

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The FTC has sent its annual letter to the CFPB reporting on the FTC’s activities related to compliance with the Equal Credit Opportunity Act and Regulation B. The FTC has authority to enforce the ECOA and Reg B as to...more

Morrison & Foerster LLP

The CFPB & UDAAP: A "Know It When You See It" Standard? 2015 Year-End Update

The Consumer Financial Protection Bureau’s (CFPB) exercise of its sweeping authority to prohibit unfair, deceptive, and abusive acts or practices (UDAAP) continues to command the attention of financial institutions and...more

Morrison & Foerster LLP

CFPB Takes Action Against Lead Aggregators

Morrison & Foerster LLP on

On December 17, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced that it has taken action against lead aggregators that resold sensitive personal information to lenders and debt collectors. In a complaint...more

Ballard Spahr LLP

CFPB enters into consent order with operator of consumer lead resale business

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The CFPB announced last week that it has entered into a consent order with an individual who had operated a defunct business that resold consumer leads to settle charges that the business sold leads to debt collectors who...more

Ballard Spahr LLP

Is Online Lead Generation Inherently Deceptive?

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This post is the third in a series we’re writing on the FTC’s workshop on online lead generation entitled Follow the Lead. In our first post, we explored how online lead generation works. In our second, we covered the role...more

Ballard Spahr LLP

The Five Stages of Online Lead Generation

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On October 30, the FTC presented a workshop on lead generation entitled Follow the Lead. Online lead generation is an area receiving increased regulatory scrutiny by the FTC and other regulators, including the CFPB. Over the...more

Ballard Spahr LLP

Lead generator files petition to set aside CFPB CID

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A lead generation company and its employee recently filed a petition with the CFPB to modify or set aside a civil investigative demand (CID). Among the arguments made in the petition for why the CID should be set aside is...more

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